How To Address the Administrative Burdens of Accessing the Safety Net

A family loses Medicaid coverage just weeks before their 4-year-old’s critical surgery because of new Medicaid renewal filing requirements they did not know about.¹ A person with a chronic illness is denied food stamps because the state agency omitted their apartment number on important letters; it takes 10 weeks of calling, documenting, and appealing to reverse the denial.² A low-income mother drops out of Women, Infants, and Children (WIC) program assistance for her infant child because she fears catching COVID-19 on public transportation, which she must take to reload her card in person.³ A man has his unemployment benefits withheld by the state because of an error on a form that caused an accidental overpayment nine years earlier.⁴

Three in five Americans will experience poverty in their adult lives.⁵ Living in or near poverty often comes with significantly more instability and less control over one’s day-to-day life.⁶ Unfortunately, this uncertainty is often made worse by an inconsistent safety net that creates onerous, unnecessary barriers to receiving vital assistance that can help low-income individuals and families both survive and escape spells of poverty. These government-imposed obstacles are known as “administrative burdens.”⁷ Broader than any specific program or benefit, administrative burdens refer to any challenge imposed on people that makes it significantly more difficult to access or maintain a benefit for which they would otherwise be eligible. Some governments also impose administrative burdens on certain activities they seek to restrict, such as voting, abortions, and adoptions by same-sex couples.⁸

This report illustrates the many forms that administrative burdens can take, the serious harms they cause, and the broad pathways for solutions that are available to reduce burdens on individuals across safety net programs, including the important steps that the Biden administration has already taken.⁹ While some programs are administered federally, others are administered at the state or local level, some with and some without federal guidance. Thus, there is an opportunity and onus for policymakers at all levels of government to reduce administrative burdens.

The pathways for solutions described in this report include:

• Executing outreach and marketing efforts to increase awareness of benefit availability
• Reducing onerous paperwork and in-person interview requirements
• Streamlining the application processes across and within programs
• Reducing the frequency and difficulty of recertification requirements
• Removing asset tests and asset limits
• Cutting work requirements
• Increasing coordination of programs at state and federal levels
• Properly funding and staffing benefits agencies so they are able to process claims efficiently

As elements of program design, administrative burdens are typically sold as measures to weed out ineligible people and prevent fraud. Yet by focusing more on preventing so-called undeserving people from accessing benefits than on simply delivering vital services, policymakers have created so many hoops that participants must jump through that those who need help most are far too frequently denied it.¹⁰ Worst of all, administrative burdens perpetuate inequity because they tend to be most heavily placed on supports for low-income people, rather than those that serve the population as a whole. As a result, more often than not, administrative burdens fall hardest on people of color, people with disabilities, women, LGBTQ people, and the elderly.¹¹ Consequently, they come with significant economic costs, not savings: The economy is weaker when those who are eligible for support are prevented from receiving it, excluding people and communities from spending, safety, and stability.

Without significant and sustained progress on easing administrative burdens in the safety net, many of the people most in need of help will continue to be cruelly excluded because of needless barriers completely unrelated to their eligibility, with themselves, their families, and the entire economy suffering as a result.

Administrative burden experts Donald Moynihan, Pamela Herd, and Hope Harvey group the costs that administrative burdens impose on people into three categories: learning, psychological, and compliance.¹²

• Learning costs are rooted in the complexity embedded in the system and the difficulty of understanding how to navigate it, as well as the need to simply be aware of the program and its eligibility rules in order to benefit from it.
• Psychological costs stem from the stigma of receiving government assistance and the stress and loss of autonomy experienced by applicants and participants. Low-income people are often shamed—frequently with substantial racist¹³ and ableist¹⁴ undertones—for needing and seeking assistance from the government.
• Compliance costs result from the effort needed to complete the paperwork, interviews, travel, phone calls, documentation, and other requirements necessary to adhere to administrative rules and keep one’s benefits. These costs have also been called a “time tax,”¹⁵ representing the hours, days, weeks, or even years needed to wade through the system. This can include filling out countless forms, placing calls repeatedly only to sit on an endless hold, spending time finding difficult-to-obtain documentation, and going through the whole process every few months for frequent recertifications.

These costs can manifest in many ways, but they all serve to frustrate, discourage, and deter. The sheer amount of paperwork frequently results in errors and unfinished applications.¹⁶ In fiscal year 2017, for example, Americans spent a collective 11.5 billion hours on paperwork requirements from just federal agencies¹⁷—an average of 45 hours per adult.¹⁸ However, that burden is unevenly distributed, as it is likely that many people spent the equivalent of two full work weeks or more filling out paperwork, while others spent little to no time at all.

Moreover, paperwork can often be inaccessible if it is not clearly written in plain language; if translated versions are unavailable; if it does not consider the needs of people with specific vision, auditory, or cognitive impairments; or if staff are unavailable to offer assistance in a timely manner.¹⁹ Online forms can also be overly difficult to navigate, especially for the elderly and others without reliable access to the internet.²⁰ Finding specific documentation can be challenging as well, particularly for low-income, elderly, or disabled people.²¹ Meanwhile, obtaining the proper identification necessary for some benefits’ use can be especially difficult for transgender and gender-nonbinary individuals.²²

Notably, the use of only physical mail for some important benefit recertifications is a huge flaw, as about a quarter of Americans from across the income spectrum report having unopened mail.²³ In addition, changing addresses frequently—which lower-income people are more likely do²⁴—leads to mail getting lost and, therefore, crucial paperwork left unfiled. For instance, Colorado sends about 12 million letters to participants of public assistance programs each year but estimates that about 15 percent, or 1.3 million, of those letters get returned as undeliverable.²⁵ Meanwhile, Missouri kicked 70,000 people off Medicaid in 2018, but about 60 percent of that group only lost coverage because they did not reply to a mailed renewal form, and more than 20,000 lost coverage because the state just could not find them.²⁶

Disabled individuals often have to balance time and energy between caregiver schedules, public transportation, and medical appointments, along with their regular daily living concerns. Many disabled people rely on paratransit, which is riddled with performance issues, forcing them to schedule at least 24 hours in advance, as they are unable to access a more regular bus or train schedule.²⁷ Paratransit users typically have to schedule windows for pickup rather than specific times and are still frequently subject to late arrivals,²⁸ which could result in them being late to important evaluations, appointments for benefit renewals, and even work, putting their benefits and jobs at risk.²⁹ Meanwhile, funding for service delivery at the Social Security Administration (SSA)—which distributes Social Security Disability Insurance (SSDI)—is increasingly being redirected toward disability reviews that often merely remove benefits for people who cannot make it through the slog of paperwork.³⁰

The stigma society places on low-income people seeking assistance—who are often characterized as “undeserving”³¹—is, alone, enough to deter many people, but the systems and processes they are legally obligated to endure before receiving aid often reinforce and exacerbate that stigma. Moreover, the questions and requirements—such as drug tests, disclosure of private medical information, and frequent in-person interviews³²—for applications and recertifications can be highly intrusive and demeaning, while the huge stakes of minor errors on time-consuming forms can cause immense stress, which can negatively affect both mental and physical health.³³

People eligible for a benefit or program often fail to achieve full—or even modest—participation because of the lack of effective community outreach and education. Many people either do not know about programs, incorrectly think they are ineligible, or assume the benefit is too small to be worth all the hassle, which it sometimes is.³⁴ Indeed, one study found that 43 percent of those eligible for the EITC did not know about it, and 33 percent incorrectly thought they were ineligible.³⁵ These systems are tricky to understand and navigate, even for people who should be experts on them.³⁶ Compliance costs can be both physical—work, time, and energy—and financial, such as lost wages or the child care, transportation, and third-party assistance costs needed to complete requirements on time. Another study found that having service providers assist applicants with completing forms increased SNAP applications by 80 percent.³⁷ Clearly, it would be beneficial to do more community outreach and provide more navigators to spread awareness and ease the process of accessing benefits for participants.

Each cost makes people less likely to complete the application process or maintain their benefits. Unsurprisingly, then, administrative burdens have been shown to directly reduce recipiency rates in safety net programs. In fact, a survey of people eligible for but not participating in SNAP found that 40 percent were deterred by the paperwork involved and another 37 percent noted that the application was too time-consuming given their family and work responsibilities; other studies found that new income documentation and in-person interview requirements decreased participation.³⁸ Likewise, the stigma for using WIC and the learning curve for identifying WIC-allowable items have been shown to likely lead to the program’s underutilization.³⁹ Moreover, in June 2018, Arkansas instituted work requirements within the Medicaid program for 30 to 49 year-olds, and by December, 17,000 had lost coverage, despite more than 95 percent appearing to meet the requirements to qualify for an exemption.⁴⁰ This drop was mostly caused by confusion over the reporting process and who the new work requirements actually applied to.

Losing access to benefits comes with serious consequences for people’s well-being, regardless of how benefits are lost. Cash assistance—be it in the form of the EITC, CTC, UI, SSI, or TANF—and other in-kind benefits, such as Medicaid, SNAP, and housing vouchers, have been proven to directly reduce poverty⁴¹ and, as a result, improve educational attainment, increase future employment and earnings, and improve health and development in the near and long term for adults and especially for children.⁴² By decreasing recipiency of aid for those who need it most, administrative burdens inflict significant harm on individuals’ and families’ well-being while also causing stress as a result of having to deal with those burdens—which has its own considerable negative health effects.⁴³

Administrative burdens are also harmful to society as a whole. When members of a community do not receive the benefits for which they are eligible, economic stability and growth suffer.⁴⁸ Consumer spending will decline if benefit-eligible populations do not have the support they need from safety net programs such as UI, the EITC, or the CTC.⁴⁹ And costs to communities may increase as individuals experience emergencies that could have been prevented had they initially received more support. For example, expanding Medicaid and reducing burdens that obstruct people from signing up can steer them toward more preventative and primary care, which costs less than future emergency room visits when conditions do not get treated properly.⁵⁰

Administrative burdens create inefficiency and waste in government. Benefits for low-income people—when they are accessible—get spent almost immediately, stimulating the entire economy.⁵¹ Moreover, reducing administrative burdens can make it easier for workers to pursue or maintain employment because it reduces the time and energy spent getting help just to meet basic needs. Indeed, when a person has their basic needs met, they are more productive on the job or in the job search, which ultimately leads to productivity gains throughout the economy.⁵² On the other hand, when individuals experience significant burdens when trying to access aid, it decreases their trust in the government to solve problems and provide meaningful assistance⁵³ and can create additional stigma for recipients of safety net programs.⁵⁴

For many reasons, the costs imposed by administrative burdens fall particularly hard on low-income people. For one, low-wage workers tend to have hourly jobs with less control over their schedules, more fluctuation in their schedules week to week, and no paid time off, making it much harder to attend appointments that are only available during work hours, especially on short notice.⁵⁵ One study found that SNAP participants given recertification interviews late in the month in which their certification period ended are 22 percent less likely to keep their benefits because they have less time to reschedule or find needed documentation after the interview.⁵⁶

Volatile hours or a reliance on tips can also make it more difficult to report and project income on forms and reliably meet work requirements, while temporary decreases or increases in hours can result in lost benefits and require a time-consuming reapplication process.⁵⁷ Studies have found that workers with unexpected hours or limited schedule control are significantly more likely to lose child care subsidies, which makes them less able to work.⁵⁸ Meanwhile, low-income workers’ lack of reliable access to transportation, child care, and internet, among other things, simply puts more roadblocks in the way of them receiving and keeping benefits, especially for programs where in-person interviews are required for enrollment or recertification or where forms must be submitted either physically or digitally, but not both.⁵⁹

Benefits for programs that are used more often by the rich and white or that are at least more universal—for instance, Social Security—are typically much simpler to access, navigate, and maintain⁶⁰ than those that primarily help low-income households, which are more likely to include people of color, disabled people, and LGBTQ people.⁶¹ For example, the mortgage interest deduction—84 percent of which goes to the top 20 percent of households⁶²—requires completing just a few lines on annual tax filing forms,⁶³ while housing vouchers and other rent assistance for low-income homes are so underfunded that waitlists are typically thousands of people and yearslong, with only one-quarter of eligible households receiving the aid.⁶⁴ Likewise, Medicare is accepted by more doctors than Medicaid because it is less burdensome and pays better for services.⁶⁵

Overall, most government benefits available to upper- and middle-income Americans are accessed through the tax code, either when filing annual income taxes or simply through employer-based benefits, which are hardly noticeable.⁶⁶ These include charitable deductions, state and local tax (SALT) deductions, 401(k) plans with employer matches, and tax-free flexible spending accounts. Although low-income workers can sometimes access those benefits as well, they more often work for employers with worse benefits and do not earn enough to claim itemized income tax deductions,⁶⁷ most of which go to the top income brackets—with the exception of some low-income tax credits such as the EITC and CTC.⁶⁸ Furthermore, higher-income households can easily claim multiple tax deductions at once, but low-income Americans typically have to complete separate applications for SNAP, TANF, Medicaid, WIC, and any other benefits they may need and are eligible for, each of which can take hours or days to complete.

Because of this designed simplicity, many middle- and higher-income Americans never have to think much about the benefits they are receiving:⁶⁹ According to one survey, 64.3 percent of people using tax-free education savings plans and 60 percent of those receiving the mortgage interest deduction claim they “have not used a government social program.”⁷⁰ Meanwhile, only about a quarter of people receiving SNAP, TANF, and subsidized housing made the same claim, and Medicaid users were 12 percentage points more likely to say they had received a government benefit than Medicare recipients.⁷¹

Because administrative burdens fall disproportionately on low-income households and safety net participants, their harms most affect women, people of color, disabled people, and LGBTQ people.⁷² Therefore, administrative burdens exacerbate inequity throughout society, among both class and demographic groups. These inequities are intentional.

Administrative burdens are often deliberately placed on certain programs because the more arduous the process is, the fewer people will complete it, regardless of eligibility.⁷³ It is a subtle way for politicians—most often conservatives⁷⁴—to reduce government spending on low-income households while undermining support for those same programs by convincing the public that they are ineffective, without the blame coming back to the politicians themselves.⁷⁵

Often, particularly onerous administrative burdens are the result of historic racism or other biases against the most common participants in a program.⁷⁶ For example, many policies that have created barriers to receiving assistance from TANF—as well as its predecessor, Aid to Families with Dependent Children (AFDC)—such as harsh work requirements and even restrictions on sexual activity, were rooted in racist stereotypes about Black mothers, exemplified by safety net opponents’ use of the stigmatized term “welfare queens.”⁷⁷

States are also incentivized to keep enrollment low as a short-term cost-cutting measure. During the COVID-19-induced recession, for example, the governor of Florida admitted that the state UI system’s horribly slow response to the spiking number of unemployed was the result of “pointless roadblocks” previously put in place by the state to “to lead to the least number of claims being paid out.”⁷⁸

Chronic underfunding of agencies tasked with distributing benefits—either via budget cuts or years of flat funding in the face of rising demand—is another political choice that imposes significant administrative burdens. By allowing agencies to become severely understaffed, lawmakers create massive backlogs and wait times, which ultimately leads to far fewer people receiving the benefits they need to survive. Staff at the SSA call center declined by 12 percent from 2010 to 2019, despite call volume growing by 6 percent; as a result, the average wait time was six times higher in 2019 than it was in 2010.⁷⁹ Meanwhile, the median wait time for an appeal for SSDI benefits has improved from its peak of 839 days in 2015, but it was still at 506 days in 2019.⁸⁰

Sadly, the consequences of these political decisions can be deadly for those affected. From 2008 to 2019, the Government Accountability Office (GAO) found that 110,000 people died waiting for a decision on their appeal after an initial denial of Social Security disability benefits, while 50,000 filed for bankruptcy waiting for an appeal between 2014 and 2019.⁸¹ The troubles are only compounded during a crisis such as COVID-19. A projected half-million fewer Americans were awarded SSI or SSDI benefits in 2020 and 2021 because of SSA office closures across the country that were not accompanied by other accommodations for applicants.⁸² The disorder and lack of preparedness after years of disinvestment in the UI system also meant that an additional 7.8 to 12.2 million newly eligible people could have filed for UI benefits in the first weeks of the pandemic but could not get through the system.⁸³

Political decisions created these quagmires, and it will take political will and action to solve them.

Many experts, journalists, and career bureaucrats have been ringing the bell on administrative burdens for some time, and the Biden administration has clearly been listening.⁸⁴ On his first day of office, President Joe Biden signed an executive order that broadly covered racial equity but also contained two sections instructing all federal agencies to assess barriers to accessing and fully using government benefits and services.⁸⁵ The executive order called for a report to the president assessing barriers to full and equal participation in government programs created by government policies. This report was published in July 2021 and included a section titled “Administrative burden exacerbates inequity,” offering 37 potential solutions to reducing known burdens, including by providing additional assistance with applications; cutting wait times, in-person interviews, and recertifications; and using broad categorical eligibility and automatic enrollment.⁸⁶

The White House’s most significant step toward addressing administrative burdens was another executive order, signed in December 2021, focused on “customer experience and service delivery.”⁸⁷ This order detailed 36 mandated actions across 17 federal agencies to reduce administrative burdens and improve Americans’ experience with the government.⁸⁸ Among the most notable of those actions was reducing paperwork for safety net benefits by automatically certifying income eligibility for enrollments and renewal; streamlining safety net programs with an online platform; and a “no-wrong door” policy in which interacting with one federal program can connect and automatically enroll a person with any others for which they are eligible.⁸⁹

Following up on President Biden’s December 2021 executive order, the U.S. Office of Management and Budget (OMB) issued a memo to all federal agencies in April 2022 providing guidance on how to apply the Paperwork Reduction Act of 1995 to reduce administrative burdens.⁹⁰ The memo instructs agencies to work with the public—specifically users of the programs—to fully understand the “time, financial, and psychological costs” imposed from the beginning to the end of a user’s experience. Moreover, it encourages agencies to follow leading practices on reducing burdens, including by simplifying paperwork requirements, enhancing outreach, improving options for how required information can be submitted, and using top user-centered design practices on forms, communications, and web platforms.⁹¹

Beyond these encouraging developments, the Biden administration has also taken concrete steps to ease some administrative burdens by reversing work requirements on Medicaid; increasing funding for Navigator programs, which helps people sign up for Medicaid, CHIP, and ACA marketplace health insurance; relaxing documentation requirements for rental assistance; and simplifying rules for the Public Service Loan Forgiveness program.⁹²

Many states have also been active in reducing burdens in their safety nets. Minnesota, for example, created a website with streamlined applications and forms for nine safety net programs in an effort to significantly reduce time spent on paperwork and increase take-up of multiple programs for eligible residents.⁹³ Michigan also implemented some reforms that made renewal applications for health care, food assistance, child care, and cash assistance benefits 80 percent shorter and cut their processing time nearly in half, resulting in significantly more completed and successful applications, fewer errors and office visits, and potentially 200,000 hours saved for caseworkers each year.⁹⁴ Likewise, Massachusetts passed legislation in 2021 eliminating all asset limits on TANF and Emergency Aid to the Elderly, Disabled and Children (EAEDC) in the state.⁹⁵

Improvement to individual administrative burdens in individual programs is much needed, but any upgrade by itself will be insufficient long term without a cultural change, within the bureaucracy and among politicians designing programs, that emphasizes efficiency, user experience, and participation. There needs to be a pervasive desire in government to shift as many burdens as possible off of individuals and onto the state.⁹⁶ The Biden administration is leading this effort and should continue to expand its attempts to reduce administrative burdens as it seeks to make lasting change that will outlive the administration. State, territorial, tribal, and local governments should all follow this federal example and seek to reduce burdens on any safety net programs, benefits, and services they are responsible for administering.

The potential solutions to administrative burdens are too numerous and specific to individual services and programs to list entirely. Yet the following broad, nonexhaustive categories of actions would ease administrative burdens in any program to which they are applied:

• Executing outreach and marketing efforts to increase awareness of benefit availability: Overcoming learning costs by ensuring that everyone is informed about all the supports they are eligible for and by providing assistance in navigating what is often a confusing process would be a huge first step in ensuring higher participation.
• Reducing onerous paperwork and in-person interview requirements: Much of the information the government needs from an applicant should already be on file, making excessive paperwork and documentation a burden on individuals that the state could more easily and efficiently bear. Many in-person interviews—which are proven to reduce participation, as they can be challenging to attend when low-income individuals lack reliable transportation or child care and face inflexible work schedules—could be replaced with phone calls.⁹⁷ Reducing these burdens would also significantly free up workers at government agencies to spend their time more efficiently.⁹⁸
• Streamlining the application processes across and within programs: Anyone interacting with a safety net program or other benefits should be informed about and be able to quickly and easily apply to all benefits for which they would be eligible. While many programs have different qualifications and eligibility rules that would need to be consolidated considerably before applications could be condensed into one form,⁹⁹ the increased efficiency and recipiency from doing so would be hugely important.
• Reducing the frequency and difficulty of recertification requirements: Mandating frequent recertifications to maintain benefits is a major cause of dropouts. In California, the majority of people leaving SNAP were found to still be eligible.¹⁰⁰ Renewals should be made as simple and automatic as possible, with the least lift required from participants.
• Removing asset tests and asset limits: Beyond creating a cliff that traps people in poverty, asset tests also create onerous paperwork and documentation requirements, forcing low-income households into the time-consuming and error-prone process of documenting every one of their assets. For this reason, asset tests tend to significantly decrease participation in safety net programs.¹⁰¹
• Cutting work requirements: Work requirements have not proven to increase work participation in the long run¹⁰² and, similar to asset tests, serve more as paperwork requirements that inevitably cut off benefits for some eligible participants because the paperwork is too confusing, time-consuming, or otherwise difficult to consistently complete.¹⁰³
• Increasing coordination of programs at state and federal levels: Similar to streamlining programs, a lot of information needed to determine eligibility may be held by multiple agencies or departments. Coordinating the sharing of that information automatically would be challenging but hugely beneficial. The federal government also has significantly more resources and funding than individual states or localities, so any additional information or administrative help it can provide would be a boon to the process.
• Properly funding and staffing benefits agencies so they are able to process claims efficiently: Underfunding and understaffing have been major causes of long wait times and applicants’ inability to receive assistance in numerous programs.¹⁰⁴ Benefits agencies need to be funded and staffed sufficiently so that they can help applicants and recipients in a timely manner when issues arise, especially during economic downturns and mass disabling events—such as the COVID-19 pandemic—when a rush of applicants flood the system.

Aside from reforms to asset tests, work requirements, and funding, these changes can primarily be undertaken via executive authority, although that may vary depending on the program or service. Just as the federal effort to reduce administrative burdens is being run through the OMB, states and localities should start by centralizing responsibility with a commission or coordinating body that can lead this work, studying, developing, and managing progress toward the recommendations across the government. Speaking to and testing processes with actual users will also be crucial to ensuring that administrative burdens are being reduced without creating new ones.

While fraud should not be totally ignored, emphasizing it above all else has come at the cost of making it far more difficult for anyone to receive assistance, blocking eligible individuals who need help most but are unable to overcome the administrative burdens.¹⁰⁵ Long term, Congress and state legislatures must work to create more universal programs with minimal means testing, putting the emphasis more on distributing benefits than ensuring that they only end up with so-called deserving people.

Administrative burdens exacerbate poverty and inequity by disadvantaging those with less financial means, physical ability, time, and systemic knowledge to navigate the system—or just avoid it altogether—and by discouraging or outright denying those who need the help most. This inequity is worsened because local agencies for safety net programs with the most low-income nearby residents frequently have the least capacity for handling and reducing administrative burdens,¹⁰⁶ as well as because burdens are placed more extensively on people with low incomes, people of color, disabled people, LGBTQ people, and the elderly. Finally, administrative burdens weaken the economy as a whole by reducing people’s time and ability to spend and work.¹⁰⁷

It is simply not enough for the safety net to exist. People need to be able to easily and quickly access it. The only way to ensure that they can is by acknowledging and thoroughly addressing administrative burdens.

Acknowledgments

The author would like to thank Arohi Pathak, Lily Roberts, Marina Zhavoronkova, Mia Ives-Rublee, Emily DiMatteo, Jill Rosenthal, Caroline Medina, Nicole Lee Ndumele, Willliam Roberts, David Ballard, Nick Buffie, and Seth Hanlon of the Center for American Progress for their incredibly valuable input on this report. Ashfaq Khan and Anona Neal provided thorough and helpful fact-checking.